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this process. Electronic TWIC readers are the next chapter in the TWIC saga. PVA Þ rmly believes that TWIC readers are not necessary to ensure security aboard U.S. passenger vessels and would interfere with day-to-day operations, fail to provide additional security and, as a result, would impose unnecessary expense. After participating in a very thorough pilot study, three PVA member companies independently reported that that they had derived no security enhancements due to using TWIC readers. Reaching beyond the continuing issue of TWIC and TWIC readers, passenger vessel operators are experiencing growing frustration with the Coast GuardÕs marine casualty reporting process. When to Þ le a form 2692 and when not to Þ le is a point of confusion that is not fostered by unclear regulation but rather by inconsistent application of that regulation by Coast Guard personnel. In some ports, the Coast Guard requires a form 2692 be Þ led for incidents that are not related in any way to the operation of the vessel. In other ports, there are different standards. Over reporting has many related costs. The costs of unnecessary crew drug testing, management time to report non-incidents, costs of vessel delays caused by investigating minor incidents, and most importantly, costs related to potential damage to corporate reputations when press and others draw inaccurate conclusions about a companyÕs safety record. In addition, there is the potential for punitive Þ nes. PVA is working with Coast Guard leadership to solve this ongoing problem, yet we need relief and the consistent national application of policy soon. I am enthusiastic about the future for the passenger vessel industry and the maritime industry at-large. We have intelligent, creative and hard-working individuals engaged day-in and day-out in the pursuit of excellence for our companies. The contribution that they make as maritime workers is fundamental to our NationÕs improving health. With the understanding and support of government partners, such as the Coast Guard, in working with us to ensure a balanced and reasonable approach to regulation, we can most assuredly be conÞ dent about our future. www.marinelink.com MN 21MNOct2012 Layout 18-31.indd 21MNOct2012 Layout 18-31.indd 2110/2/2012 9:34:34 AM10/2/2012 9:34:34 AM
